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Management Structure

Anti-Corruption

Policy

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The Tokyu Fudosan Holdings Group recognizes that corruption and bribery are serious risks that could considerably damage the trust and credibility of a company.

Policy

The Tokyu Fudosan Holdings Group recognizes that corruption and bribery are serious risks that could considerably damage the trust and credibility of a company. We are committed to maintaining sound relationships with stakeholders and will never engage in business entertainment or gift-giving that elicits suspicion or mistrust from society. Specifically, we will thoroughly implement the following.

  1. We will never engage or be complicit in any and all forms of bribery, including money laundering, embezzlement, or obstruction of justice, etc.
  2. In fully understanding laws and regulations about relationships with public offices and other similar persons in Japan or other countries, we will never engage in business entertainment or gift-giving that elicits suspicion or mistrust from society and we will never provide monetary or other benefits to gain illicit profits.
  3. We will not provide or receive business entertainment or gifts from business partners or other parties that deviates from sound business practices or social norms.
  4. We will not use our position or authority to demand personal benefits from our business partners or other parties.

In addition, a code of conduct is stipulated in the code of ethics for executive officers approved by the Board of Directors Meeting to counteract all corruption activities including bribery.

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Tokyu Fudosan Holdings

Management Structure

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The Group has established the Compliance Helpline, as an outlet for all employees to report any violation of laws,

Management Structure

Whistleblower System

The Group has established the Compliance Helpline, as an outlet for all employees to report any violation of laws, company rules, and the Code of Conduct directly to the General Manager of the Group Legal Affairs Department or an outside lawyer. The Tokyu Fudosan Holdings Group Compliance Manual defines the Group's conduct based on five themes: 1) Compliance with Laws and Regulations and Fair Trading; 2) Ensuring Customer-oriented Awareness; 3) Suitable Execution of Duties; 4) Proper Management of Information; and 5) Ensuring Good Faith in Business Conduct. Particularly, number 5, which reads ensuring good faith in business conduct, further defines specific behavior guidelines, including 1) reasonable business entertaining and gift-giving, 2) prevention of corruption and bribery, 3) entertaining and gift-giving involving politicians and civil servants, and 4) code of behavior for deemed civil servants, in order to counteract all forms of corruption and not just bribery. More details about the Compliance Helpline can be found in the Tokyu Fudosan Holdings Group Compliance Manual.

Thorough dissemination of information to employees

The Tokyu Fudosan Holdings Group Compliance Manual defines the Group's code of conduct based on five themes: 1) Compliance with Laws and Regulations and Fair Trading; 2) Ensuring Customer-oriented Awareness; 3) Suitable Execution of Duties; 4) Proper Management of Information, and 5) Ensuring Good Faith in Business Conduct. More specifically, theme 5. Ensuring Good Faith in Business Conduct has further defined behavior guidelines, including 1) reasonable business entertaining and gift-giving, 2) prevention of corruption and bribery, 3) entertaining and gift-giving involving politicians and civil servants, 4) code of behavior for deemed civil servants, in order to counteract all forms of corruption and not just bribery. Employees can review this code of conduct on the Intranet at anytime.

Every year, e-learning on compliance is conducted targeting all employees. The learning program features questions related to laws and code of conduct, as well as refreshes employees' understanding of the Tokyu Fudosan Holdings Group Compliance Manual and Whistleblower System. Questions on elements of anti-corruption, including bribery, are posed to promote well-spread recognition and understanding, as well as to encourage active communication between all employees.

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Tokyu Fudosan Holdings

Compliance training

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The Group conducts various compliance seminars targeting all employees on a regular basis.

Compliance training

The Group conducts various compliance seminars targeting all employees on a regular basis. In May 2016, an outside lawyer was invited to give a lecture on Prevention of Accounting Fraud and Compliance. In this seminar, the lecturer also defined demands for personal interest using one's position, and receipt of entertainment and gifts.
Six workshops were held from April to December in 2017, and a total of approximately 600 people participated. Three more workshops are scheduled from January to March in 2018.  In addition, e-learning training was conducted once and about 20,000 people attended (attendance rate 96.7%).

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Tokyu Fudosan Holdings
Management Structure
Anti-Corruption
Response thumb card management

Policy

The Tokyu Fudosan Holdings Group recognizes that corruption and bribery are...

Management Structure
Anti-Corruption
Response thumb card management

Management Structure

The Group has established the Compliance Helpline, as an outlet for all emp...

Management Structure
Anti-Corruption
Response thumb card management

Compliance training

The Group conducts various compliance seminars targeting all employees on a...

Management Structure
Risk Management
Response thumb card management

Policy

The Tokyu Fudosan Holdings Group has established the Basic Regulations on R...

Management Structure
Risk Management
Response thumb card management

Management Structure

Article 4 of the Basic Regulations on Risk Management stipulates that the c...

Management Structure
Risk Management
Response thumb card management

Reserve Fund for Legal Violations and Litigation

At the end of every fiscal year, Tokyu Fudosan Holdings estimates the amoun...

Management Structure
Information Security
Response thumb card management

Policy

The Tokyu Fudosan Holdings Group formulated the “Information Management Pro...

Management Structure
Information Security
Response thumb card management

Management Structure, Practice and Implementation (Protection of personal information)

Each Group company develops policies, regulations, and manuals concerning t...